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Draft Supplemental Environmental Impact Report Page IV.D-29 Forward Inc. Landfill 2018 Revised Project The flare scenario (Project compared to Current Actual)and the LFG Engine scenario (Project compared to Current Actual)both would exceed the threshold of 25,000 metric tons/year of CO2e, indicating substantial emissions of GHGs under these scenarios. The LFG Engine scenario would result in power displacement and thus, its GHG emissions would be slightly less than the flare scenario. Lastly (Item C), the project would be in compliance with CARB regulations for landfill methane emissions. The landfill methane emission rule regulates emissions from the landfill surface, landfill gas collection system,flares, and LFG engines. Compliance with a statewide plan for reduction or mitigation of GHG emissions would render this project less than significant according to the flowchart guidance provided by the SJVAPCD in the fact sheet related to addressing GHG emission impacts21; therefore a BPS is not necessary to demonstrate that GHG emissions are less than significant. The SJVAPCD has not approved BPS for landfill GHG emissions. The majority of analyses of items A through C indicate that the project would not have a significant impact on the State's goals for reducing GHG emissions. If carbon sequestration of materials in the landfill were considered as a credit against emissions,none of the scenarios would exceed the 25,000 metric ton annual limit. Also,none of the Project scenarios would exceed 25,000 metric ton annual limit when compared to the Current Permitted emissions. However, this analysis does not consider sequestration of carbon in the landfill as a credit against emissions, and therefore under both the project scenarios (Flare-Current Actual and LFG Engines-Current Actual scenarios)the project would exceed the 25,000 metric ton increase annual limit compared with actual existing emissions. Considering all three items in total and given the compliance with CARB's Landfill Methane Rule and the energy efficient location of the landfill, the project would generally be in compliance with the State's goals for reducing GHG emissions. Regardless, the project would result in an increase above the 25,000 metric ton annual limit(at the maximum acceptance rate—when compared to the current actual baseline) resulting in additional impacts in California (the project GHG emissions would be similar to emission levels from major sources). Thus, because of the emissions that would be generated from maximum operations, this impact is considered potentially significant. Mitigation Measure D.4. (Same as 2013 EIR Mitigation Measure D.5.): Both the Flare and LFG engine options would require feasible mitigation measures to further reduce GHG emissions. The landfill operators shall annually report GHG emissions from the project (actual operations) to the County and SJVAPCD. If project operations exceed 25,000 metric tons of CO2e per year by 2020, then the landfill shall purchase verifiable GHG credits to offset the remaining project emissions above 25,000 metric tons of CO2e per year. Additional GHG credits shall be purchased every five years if the annual reports indicate that the credits have not offset excess GHG emissions (those above 25,000 metric tons of CO2e per year)in the prior five years. 21 Factsheet flowchart reviewed September 3,2014 at: h!W://www.valle,a�g/Programs/CCAP/bps/Fact Sheet Stationary Sources.pdf